Integrity is a core Equinix value. All employees, officers and directors must adhere to the Equinix Code of Business Conduct. We designed our code to express our ethical values and to guide our decision-making and actions on behalf of Equinix. Equinix actively encourages all employees to speak up when they have questions or concerns related to ethical conduct.
We require regular compliance trainings for all Equinix employees on how to uphold Equinix’s ethical standards in their day-to-day decision-making and actions on behalf of our company. In 2020, Equinix’s Annual Code of Business Conduct Training reached 100% of employees globally. Additionally, all new hires completed the Code of Business Conduct and anti-bribery and corruption training courses within six months of being hired. Equinix also conducts trainings on topics related to discrimination, conflicts of interest and data security and privacy. Equinix makes trainings available in multiple languages to ensure content is accessible to all employees. Although historically we have offered live trainings in addition to online trainings, due to the COVID-19 pandemic, in 2020 we offered only online compliance and ethics and compliance trainings. We intend to resume live trainings when it is safe to do so in the future.
We are opposed to all forms of discrimination with respect to employment and occupation, modern slavery, human trafficking, forced or compulsory labor and child labor. More information about how we conduct our business around the world and the requirements we place on our partners and suppliers can be found in the Equinix Business Partner Code of Conduct.
Equinix prohibits bribery and corruption of any kind, and we work to comply with applicable anti-corruption and anti-bribery laws in all countries where we do business. The Code of Business Conduct outlines our policies and procedures to address bribery and corruption. Business Assurance Services, in close collaboration with the Ethics and Compliance Office, routinely assesses Equinix operations for risks related to corruption. Assessments include, but are not limited to, the comprehensiveness of corruption policies, the rigor of training and enforcement of policies and the sufficiency of the “tone at the top” to combat corruption.
We address all inquiries and reports of misconduct and manage the review and resolution of issues on a case-by-case basis. The Governance Committee of the Board oversees and receives regular updates on the company’s Governance Risk and Compliance (GRC) program led by the Chief Compliance Officer. The GRC also provides trend and benchmarking data to evaluate the rigor of our programs.
We regularly assess the effectiveness of our Ethics and Compliance Program to ensure we are meeting the highest standards of integrity. In 2020, we conducted a company-wide risk assessment, surveyed close to 1,400 global employees, an effort which helped assess the level of awareness of ethical issues across the business, and identified opportunities for improving our ethics and compliance program. We also participated in an annual ethics benchmarking review managed by an external third party to identify potential opportunities to improve our policies, practices and disclosures.